https://www.taxtmi.com/caselaws?id=362284 Loss on cancellation of forward foreign exchange contracts used to hedge capital investment exposure was treated as capital loss, because the contracts had already been characterised as capital in nature in earlier years and the cancellation loss followed the same character. Capital gain from sale of Indian securities by a Singapore tax resident with no permanent establishment in India was held taxable only in Singapore under Article 13(4) of the India-Singapore Tax Treaty. Article 24 did not import a remittance condition where Article 13(4) itself allocated exclusive taxing rights to the residence State, so repatriation of funds was not required for treaty protection. en-us Wed, 20 Jun 2018 00:00:00 +0530 Fri, 22 Jun 2018 08:58:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=362284 Loss on cancellation of forward foreign exchange contracts used to hedge capital investment exposure was treated as capital loss, because the contracts had already been characterised as capital in nature in earlier years and the cancellation loss followed the same character. Capital gain from sale of Indian securities by a Singapore tax resident with no permanent establishment in India was held taxable only in Singapore under Article 13(4) of the India-Singapore Tax Treaty. Article 24 did not import a remittance condition where Article 13(4) itself allocated exclusive taxing rights to the residence State, so repatriation of funds was not required for treaty protection. Case-Laws Income Tax Wed, 20 Jun 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=362284